ML20041A083

First Interrogatories & Request for Production of Documents Re full-scale Sleeving Program.Related Correspondence

ML20041A083
Person / Time
Site:	Point Beach
Issue date:	02/10/1982
From:	Patricia Anderson WISCONSIN'S ENVIRONMENTAL DECADE
To:	WISCONSIN ELECTRIC POWER CO.
References
NUDOCS 8202190071
Download: ML20041A083 (8)

Text

.

~,%

Y s RELATEn connpyg e D UED-02/10/02-P:50266N3 % 9 S UNITED STATES OF A!! ERICA N

~ BECE1VED p gjg82P dl NUCLEAR REGULATORY CO!!!!ISSION Y M the Atomic Safrty and Licennino z Board 5%* A Wisconsin-Electric Power Company '

POINT BEACH NUCLEAR PLANT UNITS 1 & 2 DOCKET NOS. 50-266 AND 50-301 Operating License Amendment (Steam Generat'or Tube Sleeving Program)

DECADE'S F RST INTERROGATORIES AND REQUEST FOR PRODbCTION OF DOCUMENTS TO LICENSEE ON THE FULL SCALE SLEEVING PROGRAM Pursuant to 10 C.F.R. S720, the Licensee, WISCONSIN ELECTRIC POWER COMPANY, is herein required to answer the following interrogatories and to produce the f o'llowing documents and to serve a copy of the documents and its answers and objections, if any, upon Peter Anderson, Director of Public Affairs, Wisconsin's Environmental Decade, 114 North Carroll Street, e

' Mson,_ Wisconsin 53703.

INSTRUCTIONS

1. Answer each interrogatory separately and fully in writing under oath, unless it.is objected to, in which event the reasons for objection must be stated in lieu of an answer.

I

2. An evasive or incomplete answer is deemed to be a f ailure' to answer.

3. You are under a continuing duty to seasonably supplement your response with respect to any questions directly addressed to the identity and location of persons having knowledge of

~. /

38 t.

l 8202190071 820210 PDR ADOCK 05000266 PDR 9

2 --

discoverable matters, and the identity of each person expected to .

be called as an expert witness at hearing.

Furthermore, you are under a similar duty to correct any incorrect response when you later learn that it is incorrect and to supplement your response with new.information.

4.

Whenever l'n these instructions or interrogatories a 3

request is made to idlentify a person (s) or source (s), state the a

name(s), and the last known address. ut 5.

Whenever in these instructions or interrogatories a request is made to " list",

. " describe", or " identify" documents, h those terms shall be interpreted as a request to provide the L documents, or, {[

if the documents cannot for good cause be 5

-E produced, to supply as to each document the following information L where such information is appropriate for each document:

s i?1

=

(a) The type of document (e.g., id letter, memorandum, report, study, etc.); 1 E_r

~-

(b) The date of the document; sm.

7**

(c) [sc The-name(s) of the sign'er(s) of the document; (d) s:r

)

The present whereabouts of the document or copy E.7 thereof and the name and address of the custodian thereof; (e)

A brief sum' mary of the subject matter of the document; and . _ . .

t:2?f

6. !5i5i As used in these instructions or interrogatories, the 5"'

in term " document" is used in a comprehensive sense and includes ,

$7 without limiting its generality of meaning, all written, typed, r=9 ll[.l.=

printed, transcribed or graphic or electronically recorded ifia

!5E-materials. _

s..

.7 ,'a:::::

Whenever in these interrogatorie7s a request is made to

Z

~ ___._ _

96

• s-=.es.

4 state any facts, basis and/or information, in addition to stating the requested facts, basis and/or information, identify the l I

natural person (s) most knowledgeable as to such fact, basis and/or f information and list all documents which relate to any such fact, basis and/or information, whether or not such person (s) {

is in the employe or under the direct control of the  !

s person answering these'interr.ogatories.

y

8. Whenever in answer to these interrogatories which seek ^

all information concerning a subject, the answer includes a  :

7 specific reference or references, clearly state whether there is any other in f o r[na ti on ,

responsive to the interrogatory not [5 included in the answer.  :

9. L Whenever in answer to these interrogatories or request -

f or production of documents a claim of privilege is asserted, state the grounds on which the claim is asserted and also clearly i identify the matters or documents for which the privilege is claimed, the general subject matter of the matters or documents h

and the name and address of persons receiving copies of the iE ih document, if any.

10.

All portions of these " Instructions" shall be deemed to "

bp part of these interrogatories and request for production of _

documents. "

-.s p' Jel

=

5:::

L 4.

e

[55 5

INTERROGliTORIES Part A Part A Interrogatories whether and the extentseeks to determine to which operational facts bearing on modifications intended to reduce steam generator tube degradation may have an adverse and effect on reactor vessel embrittlement or thermal shock visa-versa.

I

1.  !

Describe all changes in operating parameters at Point I i

Beach Nuclear Plant which have been undertaken or which are presently planned to be unde.taken in the future in order to t reduce or alleviate steam generator tube degradation subsequent to August 1,197 9.

~

2 State any and all studies, analyses or consideration of any kind given to the direct or indirect effect of any change in E operating paramaters undertaken or planned to be undertaken to "

reduce or alleviate steam generator tube degradation s on reactor vessel embrittlement or thermal shock.

3.

Describe all changes in operating parameters at Point f5.

Beach Nuclear Plant which have been undertaken or which are [7 planned to be undertaken in the future in order to reduce or K?

{

alleviate reactor vessel embrittlement or thermal shock. '**::':

4 p; State any and all studies, analyses or consideration of ..

any kind given to the direct or indirect effect of any change in ..g; operating parameters undertaken or planned to be uncertaken to .2 7

reduce or alleviate reactor vessel embrittlement or thermal shock g5 on steam generator tube degradation, ==

k

-me emoed

.2

_=:

fdlf

=-

, ihji

=-

1 i

Pa r:t J}

Part B Interrogatories seek facts to determine uhether new 1 mechanisms program. for degradation may arise f rom the full scale sleeving S.

State any and all studies, analyses or consideration of u e

any kind given to the possibility of physical contact between the sleeve and/or tube between the upper and lower joint, including but not limited to the possibility of resulting degradation to i the sleeve and/or tube.

p 6.

State any and all studies, analyses or consideration of any kind given to the possibility of galvanic corrossion occuring -

in the sleeved steam generator tubes, apart from that specifically described in the Licensee's October 27, 1981 Response to Decade's First Interrogatories on Demonstration Sleeving Program, at V8.

7.

State the preliminary and final results of tests performed (i) w to demonstrate the corrosion and/or cracking h.f resistance of thermally treated Inconel 600 to primary and/or 5:

~1

=..u water, (ii) verify the corrosion and/or cracking resistance of the transition of the lower joint of the sleeve, (iii) h.. .

to verify _ ,

the corrosion and/or cracking resistance of the upper joint of A:-

the sleeve; (iv) to verify leak limiting capabilities of the , . ,

upper joint of the sleeve, (v) to verify the structural strength 9 and leak tightness of the upper and lower joint of the sleeve .

af ter cyclical loading and during accident conditions, (vi) to ff verify the internal pressure capabilities of sleeve joint, and h

(vii) any and all tests related to sleeving either not i

specificaly referenced in the Sleeving Eeport and/or corn menced '

subsequent to preparation of the Sleeving Report; and, with 4.*.

'e1 e

[

respect to each of the foregoing, provide all details of the k tect s, i f any.

8.

State any and all studice, analyses or consideration of any kind given to the environment of either primary or secondary c water in the annulus between the sleeve and the the tub e and/or to 5 potential corrosive processes that might occur in that environment, apart from that of specifically stated in Section 6.1 the Sleeving Report or in Section 6.1 of Report. the San Onofre Repair f

w 9.

State any and all studies, .

analyses or consideration of any kind given to the effect cf the process which joins the .

.1 sleeve to the tube on the structural integrity of th 6 tube, individually or e sleeve or f

:

in combination, apart from that '

specifically stated in Section 6.1 of the Sleeving R eport

m.

or in Section 6.1 of the San Onofre Repair Report hk Part C [4 Part C interrogatories Z.'

seek inspectability of sleeved tubes. information related to the l$

g 10 State any and all studies,  ;;;.

any kind given. to the inspectability analyses or consideration of JE:

and the accuracy of inspections of sleeved tubes, b including but not limited to any 42 results of inspection of sleeved tubes in the field at any ]e nuclear electric generating plant, apart from that g specifically . . . . .

zag..

stated in Section 7 of the Sleeving Report San Onofre Repair Report. or Section 7 of the EEl

=a

=4.T:..

. EGG 5 52 u:.::.

'0

...s, eaeOq l

Part D Part D interrogatories seek information related to the adegoacy of quality / assurance control in the installation of sleeves by transient employees.

11. State the names, last known address, and job title of all persons who were employed by the Licensee or its contractors or subcontractors to perform the f all 1981 demonstration sleeving program at Point Beach Nuclear Plant Unit 1.

12. State whether any p'ersins employed to perform the fall i 1981 demonstration sleeving program at Point Beach Nuclear Plant Unit 1 were observed or were reported to have violated any of the plant's rules or procedures and provide all details of any such violation.

Eart E Part E interrcgatories seek information concerning the effects of tube defects in the free standing region of the steam generator.

13. Please list all defects in steam generator tubes at Point Beach Nuclear Plant by unit, steam generator, row, column, date observed, and percent defect observed, which were at a height of 22" or higher f rom tube end subsequent to 1975.

14. State any and all studies, analyses or consideration of any kind given to observed defects in steam generator tubes at a height of 22" or higher from the tube end subsequent to 1975.

l Part F '

Part P interrogatories seek information on the problem of loose plugs during accident conditions.

15. Please list all leaking plugs observed at Point Beach Nuclear Plant by unit, steam generator, row, column, and date ,

observed. -

t

16. State any and all studies, analyses or consideration of

. m . .

r-

)

any kind given to leaking plugs.

Part G Part G interrogatories seek inforraation concerning the details of the demonstration sleeving prograra.

1/. State any and all studies, analyses or consideration of the fall 1981 demonstration sleeving program at Point Beach

!Juclear Plant Unit 1, apart f rom that included in the Sleeving Demonstration Report.

18. State the primary-to-secondary observed leak rate in Point Beach !Juclear Plant Unit 1 subsequent to completion of the -

fall 1981 sleeving demonstration program, including but not  ;

i limited to the daily variation in such leak rate.

19. State the precise nature of the difficulty in veritying the acceptability of the cold leg of tube R27C49 af ter removing  ;

the explosive plug, including but not limited to the reason for .

difficulty in verifying that 40% tube vall thickness remained.

PRODUCTIO!J OF DOCUI!EtJTS

1. Produce copies of each document referenced in the ,

i answers to the foregoing interrogatories except for those l documents which are a part of these proceedings or the  !

I proceedings in PSCW Docket 6630-CE-20, 6630-UI-2 or 6630-ER-10 DATED at liadison, Wisconsin, this 10th day of February, 1982.

WISCOIJSI!J' S E!JVIROIJf!EIJTAL DECADE, I!JC.

By Original Signed by Petar Anderson PETER A!!DERSO11 Director of Public Affairs 114 IJorth Carroll Street Suite 208 3

Iladison, Wisconsin 53703 (608) 251-7020 j'}